I 

I I 

EEOC FORM 

715-01 

PART A - D 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

PART A 

Department

or Agency

Identifying

Information 

1. Agency Federal Highway Administration 

1.a. 2nd level reporting component 

1.b. 3rd level reporting component 

1.c. 4th level reporting component 

2. Address 1200 New Jersey Avenue, SE 

3. City, State, Zip Code Washington District of Columbia 20590 

4. Agency Code 5. FIPS code(s) TD04 110010001 

PART B 

Total 

Employment 

1. Enter total number of permanent full-time and part-time employees 2722 

2. Enter total number of temporary employees 5 

3. Enter total number employees paid from non-appropriated funds 0 

4. TOTAL EMPLOYMENT [add lines B 1 through 3] 2727 

1 
I 

EEOC FORM 

715-01 

PART A - D 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

PART C 

Agency

Official(s)

Responsible

For Oversight

of EEO 

Program(s) 

 1. Agency Head FHWA, Acting Administrator Brandye Hendrickson

 2. Agency Head Designee Executive Director, FHWA Walter Waidelich, Jr

 3. EEO Director Associate Administrator for Civil Rights Irene Rico

 4. Affirmative Employment Manager Division Manager, Administrative, Affirmative and Employment 

Programs Nikisha Pickett

 5. Complaint Processing Manager Division Manager Administrative, Affirmative, and Employment 

Programs Nikisha Pickett

 6. Other EEO Staff

 7. MD-715 Preparer Disability Program Manager Kirsten Poston

 8. Diversity and Inclusion Officer Human Resources Specialist and Diversity Program Manager 

Lafayette Melton

 9. Disability Special Emphasis 

Program Manager Disability Program Manager Kirsten Poston

 10. Hispanic Special Emphasis 

Program Manager 

Division Manager, Administrative, Affirmative and Employment 

Programs Nikisha Pickett

 11. Women's Special Emphasis 

Program Manager Special Programs Manager Nikisha Pickett

 12. Anti-Harassment Program 

Manager Anti-Harassment Pilot Program Manager Pamela Woodruff

 13. Reasonable Accommodation 

Program Manager Disability Program Manager Kirsten Poston 

2 
I 

EEOC FORM 

715-01 

PART A - D 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

PART D 

List of Subordinate Components Covered in This

Report 

Subordinate Component and Location

(City/State) CPDF and FIPS codes 

Arizona Division Office, Phoenix/AZ TD04 040370013 

Arkansas Division Office, Little Rock/AR TD04 052320119 

California Division Office, Sacramento/CA TD04 063150067 

Colorado Division Office, Lakewood/CO TD04 081435059 

Hawaii Division Office, Honolou/HI TD04 152400003 

Idaho Division Office, Boise/ID TD04 160160001 

Illinois Division Office, Springfield/IL TD04 178220167 

Iowa Division Office, Ames/IA TD04 190230169 

Louisianna Division Office, Baton TD04 220150033 

Maine Division Office, Augusta/ME TD04 230160011 

Maryland Division Office, Baltimore/MD TD04 240050510 

Massachusetts Division Office, TD04 250170017 

Michigan Division Office, Lansing/MI TD04 262700037 

Minnesota Division Office, St. Paul/MN TD04 276330123 

Mississippi Division Office, Jackson/MS TD04 28122049 

Missouri Division Office, Jefferson City/MO TD04 294040027 

New Mexico Division Office, Santa Fe/NM TD04 350710049 

New York Division Office, Albany/NY TD04 360050001 

North Carolina Division Office, Raleigh/NC TD04 373750183 

North Dakota Division Office, Bismarck/ND TD04 380370015 

Ohio Division Office, Columbus/OH TD04 391800049 

Oklahoma Division Office, Oklahoma TD04 40355017 

Oregon Division Office, Salem/OR TD04 411810047 

Pennsylvania Division Office, TD04 423500043 

South Carolina Division Office, TD04 450520063 

South Dakota Division Office, Pierre/SD TD04 462160065 

Tennessee Division Office, Nashville/TN TD04 471760037 

Texas Division Office, Austin/TX TD04 480330453 

Utah Division Office, Salt Lake City/UT TD04 491700035 

3 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

Vermont Division Office, Montpelier /VT TD04 500380023 

Virginia Division Office, Richmond/VA TD04 51260760 

Washington Division Office, Olympia/WA TD04 531590067 

Wyoming Division Office, Cheyenne/WY TD04 560100021 

Resource Center- , Baltimore/MD TD04 240050510 

Alabama Division Office, Montgomery/AL TD04 012130101 

Alaska Division Office, Juneau/AK TD04 021130110 

Connecticut Division Office, TD04 090255003 

Delaware Division Office, Dover/DE TD04 100130001 

District of Columbia Division Office, TD04 110010001 

Florida Division Office, Tallahassee/FL TD04 122940073 

Georgia Division Office, Atlanta/GA TD04 122940073 

Indiana Division Office, Indianapolis/IN TD04 182210097 

Kansas Division Office, Topeka/KS TD04 205400177 

Kentucky Division Office, Frankfort/KY TD04 211220073 

Montana Division Office, Helena/MT TD04 300590049 

Nebraska Division Office, Lincoln/NE TD04 312830109 

Nevada Division Office, Carson City/NV TD04 320050510 

New Hampshire Division Office, TD04 330070013 

New Jersey Division Office, West TD04 343380021 

Puerto Rico Division Office , San Juan/PR TD04 72-127 

Rhode Island Division Office, TD04 440190007 

West Virginia Division Office, TD04 540480039 

Wisconsin Division Office, Madison/WI TD04 552780025 

4 
I 

EEOC FORM 

715-01 

PART E 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

EXECUTIVE SUMMARY 

Executive Summary 

Mission 

The Federal Highway Administration (FHWA) is one of ten operating administrations of the U.S. Department of Transportation 

(DOT).  The top-level official of the FHWA is the Administrator, who reports directly to the Secretary of the U.S. Department of 

Transportation.  The FHWA has field offices in every State, the District of Columbia, and Puerto Rico. 

The Federal Highway Administration (FHWA) is an agency within the U.S. Department of Transportation that supports State and 

local governments in the design, construction, and maintenance of the Nation’s highway system (Federal Aid Highway Program) 

and various federally and tribal owned lands (Federal Lands Highway Program). Through financial and technical assistance to 

State and local governments, the Federal Highway Administration is responsible for ensuring that America’s roads and 

highways continue to be among the safest and most technologically sound in the world. 

Element A- Demonstrated Commitment from Agency Leadership 

The Associate Administrator for Civil Rights reports to the agency Executive Director.  On July 24, 2017, the FHWA Acting 

Deputy Administrator was installed.  The EEO policy statement was issued on 11/7/2017. EEO Policies and procedures are on 

the agency’s website at www.fhwa.dot.gov/civilrights. The agency conducts bi-annual all employee surveys. 

As a summary for the 2017, FHWA all employee survey(AES) resulted in the following improvements from the 2015 AES:

 • Supervisors in my work unit support employee development

 • Career development opportunities are adequate within FHWA

 • Learning opportunities to develop individual leadership skills are sufficiently available.

 • Career advancement opportunities are allocated fairly 

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

EEO and Diversity principles are included in the Agency’s Strategic Implementation Plan-The Performance Year 18/19 Strategic 

Implementation Plan addresses the element of Diversity and Inclusion in CC-2—Continues to be a strategic partner by ensuring 

diversity and inclusion is included in the Strategic Implementation Plan (SIP). Increasing the Agency’s Initiatives includes 

encouraging all employees to participate in at least one activity that promotes diversity and inclusion on an annual basis. 

Element C- Management and Program Accountability 

The FHWA assigned an anti-harassment coordinator and implemented a pilot anti-harassment program in the later part of FY 

17.  Mandatory anti-harassment training was delivered both in person and via webinar from April to August 2017, to more than 

90 % of FHWA employees. The agency is currently testing its interim/pilot anti-harassment program, and we will be evaluating 

this program in 2018, and thereafter we expect to develop a revised policy will include all of the EEOC’s requested elements. 

Employees received training on EEO and Reasonable Accommodations via the Departmental Office of Civil Rights during the 

summer months of FY 17.  The agency continues to work with the Departmental Disability Resource center to process and track 

reasonable accommodation requests.  Under their annual performance standards, managers and supervisors are evaluated on 

their efforts regarding equal employment opportunity. FHWA also produces an annual FHWA At-A-Glance report at the end of 

every fiscal year, which summarizes workforce demographics and trends.  The FHWA At-A-Glance report is presented to the 

entire agency through a virtual webinar.  Also, the Office of Human Resources distributes Office Profiles and Vital Information 

reports to the organizational unit leads of the agency which provide office demographics, diversity data, retirement eligibility for 

unit employees, and disability statistics. This information is used in annual workforce planning conversations between unit leads 

and their respective servicing HR Specialists to encourage strategic workforce planning and recruitment.  All FHWA unit leads 

are required to develop workforce plans at the unit level.  To support managers in their requirement, the Office of Human 

Resources has developed the FHWA Unit Workforce Planning Guide and toolkit. This easy-to-use, how-to guide is designed to 

help the unit managers with developing workforce plans for their unit. It introduces workforce planning concepts and definitions, 

includes a step-by-step guide to help managers identify and understand workforce planning challenges, and provides examples 

of each step of the process.  Furthermore, OPM’s annual Employee Viewpoint Survey is disseminated to a sample of the FHWA 

workforce, which evaluates and collects employee opinions about their job, their supervisor, and their agency. This information 

helps the agency to identify potential triggers within its workforce. 

Element D- Proactive Prevention of Unlawful Discrimination 

The Office of Civil Rights, with the Office of Human Resources and the Office of Chief Counsel, collaborated to develop Civility 

and Prevention of Harassment training, a pilot Anti-Harassment coordination process, and an Anti-Harassment policy 

statement. 

To further advance the implementation of diversity and inclusion in the Agency, FHWA continues its Diversity Champions 

initiative, which was established in 2016. This program provides a grassroots opportunity for employees, at all levels of FHWA, 

to identify and learn about diversity, inclusion, and engagement challenges in the workplace. The initiative relies on a peer-topeer approach. During the first year after implementation, the champions led 40 activities designed to foster diversity and 

inclusion.  In 2017, the agency selected and trained and additional 33 Diversity Champions for a total of 50 champions agencywide. The Diversity Champions continue to develop and employ the best practices for employee outreach and interactions to 

support and deliver diversity and inclusion initiatives.  Furthermore, the agency implemented a requirement that all employees 

5 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

complete two Diversity and Inclusion trainings by May 2018, and created and implemented the new Diversity and Inclusion 

Award category under the FHWA Administrator’s Awards. 

Element E- Efficiency 

FHWA timely submitted to the EEOC the Annual Federal EEO Statistical Report of Discrimination Complaints (EEOC Form 462) 

Also, FHWA timely submitted to Congress the Annual Notification and Federal Employee Antidiscrimination and Retaliation Act 

of 2002 (No FEAR Act) report. 

Element F- Responsiveness and Legal Compliance 

FHWA has a goal of full compliance with all EEO statutes, regulations, policy guidance, and other written instructions. Agency 

personnel are held accountable for timely compliance with orders issued by the EEOC and the Departmental Office of Civil 

Rights has implemented procedures to ensure timely completion of ordered corrective actions and timely submission of 

compliance reports. 

As of September 30, 2017, FHWA onboard strength showed a total of 2,727 employees, of whom 2,722 were permanent 

employees and 5 were temporary employees.  During FY 2017, approximately 12.42 percent of all hires were PWD, and 1.86 

percent were PWTD. The FHWA goal for hires of PWD is 10 percent, which means FHWA was above its goal.  The FHWA goal 

for onboard PWTD was 1.8 percent, and FHWA exceeded the goal for FY 2017.  Overall, PWTD comprise 2.2 percent of the 

FHWA workforce. (This number is inclusive of hires from other DOT modes, and not accounted for in the workforce tables). 

Veterans represented 17.1 percent of all hires and 9.7 percent of the total workforce in FY 2017.  Veterans with 30% or more 

disability represent 7.73 percent of all hires and 2.7 percent of total workforce. The Agency experienced a hiring freeze from 

January 2017, and thus recruitment efforts were not as expected for FY17. 

Part E.3 - Executive Summary: Workforce Analyses 

The FHWA has made strides in increasing the overall diversity of its workforce between FY 2010 and FY 2017: 

(1) Hispanics in the FHWA permanent workforce have increased from 7.82 percent to 8.33 percent 

(2) Black or African Americans in the permanent workforce have increased from 15.38 percent to 15.59 percent; and 

(3) PWD increased from 8.98 percent to 9.48 percent of the FHWA permanent workforce. 

(4) PWTD increased from 1.5 percent to 2.34 percent of the FHWA permanent workforce. 

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

Even with the increased diversity of its workforce, FHWA continues to seek ways to improve its overall diversity by reviewing 

exit survey data, utilizing feedback from its FHWA All Employee Survey, and analyzing data to determine the composition of its 

workforce. 

FHWA has identified that there is a deficiency in recruitment of Hispanic females in the workforce in comparison with the Civilian 

Labor workforce. Plans have been identified according to the FY 2017 FEORP Hispanic Employment Report to address these 

deficiencies and are included in our Parts H and I of this report.   

The Federal Employee Viewpoint Survey Indices of the Hispanic/Latino Federal workforce are as follows: 

Federal Employee Viewpoint Survey Indices  FHWA Hispanic/Latino Federal Employee Viewpoint Survey 

Index Score 

Global Satisfaction Index  74% 

Employee Engagement Index  76% 

Diversity and Inclusion  70% 

Males 

FHWA FY 2017=63.33% (1727) an increase in percentage and decrease in total number from FY 2016 =63.17% (1758) 

FY 2010 CLF = 51.84% 

Females 

FHWA FY 2017=36.67% (1000) a decrease in percentage and total number from FY 2016 36.83%(1025) 

FY 2010 CLF =48.16% 

FHWA Complaint Trends 

Over the past three years from FY 15-FY 17, the number of EEO complaints filed increased from FY 15 (13), to FY 16 (17) and 

decreased for FY 17 (15).  In FY 17, the top five bases of complaints were Disability, Reprisal, Race, Sex and Age.   The top 

issues were Reasonable Accommodation, Harassment (Non-Sexual), Evaluation/Appraisal, and Disciplinary Actions. There 

were too many issues to list tied for number five.  In FY 17, the Office of Civil Rights provided training on the EEO Counseling 

Process to managers and employees in April.  Additionally, training in the area of Civility and Prevention of Workplace 

Harassment was conducted in FY17. 

FY 2017 Top Five Bases 

Disability -5 (4-physical, 1-mental) 

Reprisal-4 

Race-4 (3-Black, 1 White) 

Sex-2 (1 Male, 1-Female) 

Age -2 

FY 2017 Top Issues 

Reasonable Accommodation- 3 

6 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

Harassment (Non-Sexual) - 3 

Evaluation/Appraisal - 2 

Disciplinary Action -2 (1 Suspensinon, 1- PIP) 

FY 2016 

Top Five Bases 

Sex- 8 (5 females, 3 male) 

Age-7 

Race-3 

Disability-3 

Reprisal -2 

Top Five Issues 

Harassment (Non-Sexual)-8 

Promotion/Non-Selection -4 

Performance Appraisal/Evaluation-2 

Training-2 

Other -2 

FY 2015 Top Five Bases 

Reprisal-7 

Race- 6 (4 Black, 2 Asian) 

Sex-4 (3 Female, 1, Male) 

Age- 3 

Color- 3 

FY 2015 Top Five Issues 

Harassment (Non-Sexual) 8 

Performance Appraisal/Evaluation-5 

Promotion/Non-Selection-4 

Disciplinary Action -3 

Assignment of Duties, Training-2 

Executive Summary: Accomplishments 

The FHWA makes equal opportunity principles a fundamental part of its culture. Some of FHWA’s FY 2017 accomplishments 

under the six essential elements (demonstrated commitment to equal employment opportunity, integration of EEO into DOT’s 

strategic mission, management and program accountability, proactive prevention of unlawful discrimination, efficiency and 

responsiveness, and legal compliance) were:

 • For the 2017 OPM’s Federal Employee Viewpoint Survey, (FEVPS), FHWA was ranked #33 out of #339 agency 

subcomponents in “Best Places to Work in the Federal Government”, published by the Partnership for Public Service. The index 

score for diversity and inclusion (New IQ index) for FHWA was 73 percent, which remained the same when compared to the 

2016 IQ index.

 • No findings of discrimination by the Equal Employment Opportunity Commission, the Merit Systems Protection Board, or 

the District Court were issued in FY 2017. 

 • In FY 2017, FHWA increased the hiring of people with disabilities and people with targeted disabilities.  Our Agency has 

established intermediate goals for 2017 at 1.8% and 2018 at 2.0%.  We hired a record 3.31% of people with targeted disabilities 

in 2017, which improved our onboard percentage from 1.5% to 2.2%.  For a second year, we surpassed our 2017 goal of 10% 

of hires being people with disabilities (targeted and non-targeted) by achieving 13.8%.

 • In FY 2017, the Diversity Management Committee selected and trained 33 new Diversity Champions for a total of 50 

champions from 46 different offices across the organization.  Given the expansion of the DMC and the addition of new 

Champions, the DMC has revamped and improved its communications.  A Communications Subcommittee was established in 

FY 2017 to lead efforts that included the development of newsletters, an all employee SharePoint site, and various leadership 

and Discipline presentations. In addition, among the most significant accomplishments this fiscal year, the DMC spearheaded 

the establishment of a new FHWA Diversity and Inclusion Award for the 2017 Administrator’s Awards program.

 • The FHWA Performance Year 18/19 Strategic Implementation Plan Addresses the element of Diversity and Inclusion in 

Strategic Item CC-2—FHWA continues to be a strategic partner by ensuring diversity and inclusion is incorporated in the 

Strategic Implementation Plan (SIP). Increasing the Agency’s Initiatives include encouraging all employees to participate in at 

least one activity that promotes diversity and inclusion on an annual basis.

 • FHWA’s advisory group called the Innovation Exchange Council (iExchange) was chartered and opened for membership in 

FY 2016.  The group continues to raise awareness of generational diversity and create an environment that embraces members 

of different generations.  In FY 2017, they expanded membership to 115 members, held several crowdsource (brainstorm) 

events, virtual speed networking events, contributed to the design and launch of an Innovation Lab in partnership with Turner 

Fairbanks Highway Research Center and the Office of Personnel Management, and continued to provide feedback to the 

Human Resource Management Council (HRMC) on various activities.

 • The FHWA supports and runs a formal, competitively announced, 6-month mentoring program to provide for the 

development of a diverse workforce and for the strengthening of skills of current and aspiring leaders.  Thirty-eight mentors and 

38 mentees from across the organization participated in the program in FY 2017. 

7 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017

 • FHWA established its first Anti-Harassment Coordination process.  This is a pilot program that involves a complaint process 

for allegations of any type of harassment in or relating to the FHWA workplace. We have developed a memorandum of the Pilot 

Anti-Harassment Coordination Process along with an approved Anti-Harassment Policy Statement. The designated Coordinator 

for FHWA is Program Analyst, Pamela Woodruff with oversight by Irene Rico, Associate Administrator for Civil Rights.

 • Additionally, FHWA Office of Civil Rights conducted annual harassment training in FY17.  This mandatory training will 

continue to be updated in emphasis and conducted every year via a series of webinars and in person sessions. Prevention is 

the best tool to eliminate harassment in the workplace. Therefore, FHWA’s training focuses on prevention and employee 

involvement in creating a civil and inclusive culture within the workplace. 

The trainings took place on the following dates:

 • In person session HQ-June 1st

 • Webinar June 14th

 • In person session Connecticut Division Office-June 28th

 • Webinar-July

 • In person session Central Federal Lands July 17th

 • Webinar July 12th

 • Webinar-July 26th

 • In person session- NY Division August 8th 

Out of the 2735 employees at FHWA, 2485 completed the training. 

Ecevutive 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:

 • Continue to increase the representation of Hispanic females, white females, Native Hawaiian or other Pacific Island 

females, American Indian or Alaska native males and females at the GS-13 through 15 grade levels by enhancing recruitment 

activities and continue to foster an inclusive environment.

 • Continue to increase the Hiring of PWTD. Target goal for FY 18 is 2.0% at both higher and lower salary levels. The 2% 

goals are “sub-goals” of the 12% goals.

 • Continue to enhance the skills and capabilities of FHWA supervisors and team leaders by ensuring leaders complete 

mandatory leadership training within one year of assuming their supervisory position.  Provide continuous agency leadership 

training throughout their tenure.

 • Continue to implement the Hispanic Recruitment Plan to attract, recruit, develop and retain Hispanic representation.

 • Continue to conduct Barrier analysis and various trend analyses on workforce profile data, major occupations, grade 

distribution, the workforce compensation reward system, and management/personnel policies, practices and procedures. 

 • Continue to enhance our partnership with the DOT Disability Resource Center (DRC) to obtain information on FHWA’s 

reasonable accommodation cases and ensure information is entered and tracked the DOT Reasonable Accommodation 

Management System (RAMS). 

 • Continue to train managers/supervisors on the Reasonable Accommodations process

 • Continue to train FHWA workforce on the EEO process.

 • Continue to include agency recruitment, advancement and retention efforts for PWTD.

 • Continue to ensure EEO counseling processes are within required timeframes.

 • Continue conducting Anti-Harassment training for supervisors, managers and all staff. 

8 
I 

EEOC FORM 

715-01 

PART F 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

CERTIFICATION of ESTABLISHMENT of CONTINUING 

EQUAL EMPLOYMENT OPPORTUNITY PROGRAMS 

 I, Associate Administrator for Civil Rights Irene Rico am the 

 (Insert official (Insert name above) 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. 

Signature of Agency Head or Agency Head Designee Date 

Signature of Principal EEO Director/Official Date 

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

EEO MD-715. 

9 
I 

EEOC FORM 

715-01 

PART G 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Essential Element A: DEMONSTRATED COMMITMENT FROM AGENCY LEADERSHIP 

Requires the agency head to issue written policy statements ensuring a workplace free of discriminatory harassment and

a commitment to equal employment opportunity. 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

Compliance Indicator 

 Measures 

EEO policy statements are up-to-date. 

Measure has been 

met 

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 

Yes No N/A 

The Agency Head was installed on 07/24/2017 The EEO policy statement was 

issued on 11/07/2017 Was the EEO policy statement issued within 6-9 X 

of the installation of the Agency Head? 

 During the current Agency Head's tenure, has the EEO policy Statement been reissued annually?

 If no, provide an explanation. 

X 

Are new employees provided a copy of the EEO policy statement during orientation? X

 When an employee is promoted into the supervisory ranks, is s/he provided a copy 

of the EEO policy statement? X 

Compliance Indicator 

EEO policy statements have been communicated to all

employees. 

Measure has been 

met 

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 

 Measures Yes No N/A 

 Have the heads of subordinate reporting components communicated support of all X agency EEO policies through the ranks? 

 Has the agency made written materials available to all employees and applicants,

 informing them of the variety of EEO programs and administrative and judicial X 

 remedial procedures available to them? 

Has the agency prominently posted such written materials in all personnel offices, 

EEO offices, and on the agency's internal website? [see 29 CFR §1614.102(b)(5)] X 

10 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

Compliance Indicator

 Measures 

Agency EEO policy is vigorously enforced by agency 

management. 

Measure has been 

met 

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 

Yes No N/A 

 Are managers and supervisors evaluated on their commitment to agency EEO

 policies and principles, including their efforts to: X

 resolve problems/disagreements and other conflicts in their respective work

 environments as they arise? X

 address concerns, whether perceived or real, raised by employees and

 following-up with appropriate action to correct or eliminate tension in the

 workplace? 

X

 support the agency's EEO program through allocation of mission personnel to

 participate in community out-reach and recruitment programs with private

 employers, public schools and universities? 

X

 ensure full cooperation of employees under his/her supervision with EEO office

 officials such as EEO Counselors, EEO Investigators, etc.? X

 ensure a workplace that is free from all forms of discrimination, harassment and

 retaliation? X 

ensure that subordinate supervisors have effective managerial, communication 

and interpersonal skills in order to supervise most effectively in a workplace with 

diverse employees and avoid disputes arising from ineffective communications ? 

X

 ensure the provision of requested religious accommodations when such

 accommodations do not cause an undue hardship? X

 ensure the provision of requested disability accommodations to qualified

 individuals with disabilities when such accommodations do not cause an undue

 hardship? 

X 

11 
I Department of Transportation/DOT Federal For period covering October 1, 2016 Highway Administration to September 30, 2017 

Have all employees been informed about what behaviors are inappropriate in the 

workplace and that this behavior may result in disciplinary actions? Describe what 

means were utilized by the agency to so inform its workforce about the penalties for 

unacceptable behavior. 

X 

The FHWA Employee 

Handbook and Table 

of Offenses and 

Penalties inform 

employees of conduct 

that is inappropriate. 

The Handbook and 

Table are posted on 

FHWA Staffnet page 

at the following links: 

http://staffnet.fhwa.dot 

.gov/opt/regulations/h 

andbook/HANDBOOK 

.HTM and 

http://staffnet.fhwa.dot 

.gov/hr/regulations/ha 

ndbook/appendix_a.ht 

m. 

Nondiscrimination 

policies are also 

posted in the 

Breakrooms. In FY 

2017, FHWA 

conducted mandatory 

anti-harassment and 

civility training via 

webinar for all 

employees. 

 Have the procedures for reasonable accommodation for individuals with disabilities

 been made readily available/accessible to all employees by disseminating such

 procedures during orientation of new employees and by making such procedures

 available on the World Wide Web or Internet? 

X

 Have managers and supervisor been trained on their responsibilities under the

 procedures for reasonable accommodation? X 

12 
Essential Element B: INTEGRATION OF EEO INTO THE AGENCY'S STRATEGIC MISSION 

Requires that the agency's EEO programs be organized and structured to maintain a workplace that is free from

discrimination in any of the agency's policies, procedures or practices and supports the agency's strategic mission. 

Department of Transportation/DOT Federal For period covering October 1, 2016 to September 30, 2017 Highway Administration 

For all unmet Measure has been Compliance Indicator measures, provide a met brief explanation in The reporting structure for the EEO Program provides the space below or the Principal EEO Official with appropriate authority and complete and attach resources to effectively carry out a successful EEO an EEOC FORM 715- Program. 01 PART H to the 

agency's status 

report 

 Measures Yes No N/A 

Is the EEO Director under the direct supervision of the agency head? [see 29 CFR The Associate 

§1614.102(b)(4)] For subordinate level reporting components, is the EEO Administrator for 

Director/Officer under the immediate supervision of the lower level component's X Civil Rights reports head official? (For example, does the Regional EEO Officer report to the Regional to the Executive 

Administrator?) Director who is 

responsible for the 

day to day 

operations, oversees 

employee matters, 

and is the highest 

level career 

employee in FHWA. 

Are the duties and responsibilities of EEO officials clearly defined? X 

Do the EEO officials have the knowledge, skills, and abilities to carry out the duties X and responsibilities of their positions? 

If the agency has 2nd level reporting components, are there organizational charts X that clearly define the reporting structure for EEO programs? 

If the agency has 2nd level reporting components, does the agency-wide EEO X Director have authority for the EEO programs within the subordinate reporting 

If not, please describe how EEO program authority is delegated to subordinate X reporting components. 

For all unmet Measure has been Compliance Indicator measures, provide a The EEO Director and other EEO professional staff met brief explanation in responsible for EEO programs have regular and effective the space below or means of informing the agency head and senior complete and attach management officials of the status of EEO programs and an EEOC FORM 715- are involved in, and consulted on, 01 PART H to the Measures management/personnel actions. Yes No N/A 

agency's status 

report 

Does the EEO Director/Officer have a regular and effective means of informing the 

agency head and other top management officials of the effectiveness, efficiency and X 

legal compliance of the agency's EEO program? 

Following the submission of the immediately preceding FORM 715-01, did the EEO 

Director/Officer present to the head of the agency and other senior officials the 

"State of the Agency" briefing covering all components of the EEO report, including 

an assessment of the performance of the agency in each of the six elements of the X 

Model EEO Program and a report on the progress of the agency in completing its 

barrier analysis including any barriers it identified and/or eliminated or reduced the 

impact of? 

13 
Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

 Are EEO program officials present during agency deliberations prior to decisions

 regarding recruitment strategies, vacancy projections, succession planning, 

selections 

X 

Does the agency consider whether any group of employees or applicants might 

be negatively impacted prior to making human resource decisions such as 

reorganizations and re-alignments? 

X 

Are management/personnel policies, procedures and practices examined at 

regular intervals to assess whether there are hidden impediments to the 

realization of equality of opportunity for any group(s) of employees or 

applicants? [see 29 C.F.R. § 1614.102(b)(3)] 

X

 Is the EEO Director included in the agency's strategic planning, especially the

 agency's human capital plan, regarding succession planning, training, etc., to 

ensure 

X 

Compliance Indicator

 Measures 

The agency has committed sufficient human resources

and budget allocations to its EEO programs to ensure

successful operation. 

Measure has been 

met 

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

 Does the EEO Director have the authority and funding to ensure implementation of

 agency EEO action plans to improve EEO program efficiency and/or eliminate

 identified barriers to the realization of equality of opportunity? 

X

 Are sufficient personnel resources allocated to the EEO Program to ensure that

 agency self-assessments and self-analyses prescribed by EEO MD-715 are

 conducted annually and to maintain an effective complaint processing system? 

X

 Are statutory/regulatory EEO related Special Emphasis Programs sufficiently X 

Federal Women's Program - 5 U.S.C. 7201; 38 U.S.C. 4214; Title 5 CFR, 

Subpart B, 720.204 X 

Hispanic Employment Program - Title 5 CFR, Subpart B, 720.204 X 

People With Disabilities Program Manager; Selective Placement Program for 

Individuals With Disabilities - Section 501 of the Rehabilitation Act; Title 5 U.S.C. 

Subpart B, Chapter 31, Subchapter I-3102; 5 CFR 213.3102(t) and (u); 5 CFR 

315.709 

X 

Are other agency special emphasis programs monitored by the EEO Office for 

coordination and compliance with EEO guidelines and principles, such as FEORP -

5 CFR 720; Veterans Employment Programs; and Black/African American; 

American Indian/Alaska Native, Asian American/Pacific Islander programs? 

X 

Compliance Indicator

 Measures 

The agency has committed sufficient budget to support

the success of its EEO Programs. 

Measure has been 

met 

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 

Yes 

Yes 

14 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

Are there sufficient resources to enable the agency to conduct a thorough barrier 

analysis of its workforce, including the provision of adequate data collection and 

tracking systems 

X 

Is there sufficient budget allocated to all employees to utilize, when desired, all EEO 

programs, including the complaint processing program and ADR, and to make a 

request for reasonable accommodation? (Including subordinate level reporting 

components?) 

X 

 Has funding been secured for publication and distribution of EEO materials (e.g.

 harassment policies, EEO posters, reasonable accommodations procedures, etc.)? X 

Is there a central fund or other mechanism for funding supplies, equipment and 

services necessary to provide disability accommodations? X 

Does the agency fund major renovation projects to ensure timely compliance with 

Uniform Federal Accessibility Standards? X 

Is the EEO Program allocated sufficient resources to train all employees on EEO 

Programs, including administrative and judicial remedial procedures available to 

employees? 

X 

Is there sufficient funding to ensure the prominent posting of written materials in 

all personnel and EEO offices? [see 29 C.F.R. § 1614.102(b)(5)] X 

Is there sufficient funding to ensure that all employees have access to this 

training and information? X 

Is there sufficient funding to provide all managers and supervisors with training and 

periodic up-dates on their EEO responsibilities: 

for ensuring a workplace that is free from all forms of discrimination, including 

harassment and retaliation? X 

to provide religious accommodations? X 

to provide disability accommodations in accordance with the agency's written 

procedures? X 

in the EEO discrimination complaint process? X 

to participate in ADR? X 

15 
I 

Essential Element C: MANAGEMENT AND PROGRAM ACCOUNTABILITY 

This element requires the Agency Head to hold all managers, supervisors, and EEO Officials responsible for the effective

implementation of the agency's EEO Program and Plan. 

Department of Transportation/DOT Federal For period covering October 1, 2016 to September 30, 2017 Highway Administration 

For all unmet Measure has been Compliance Indicator measures, provide a met brief explanation in EEO program officials advise and provide appropriate the space below or assistance to managers/supervisors about the status of complete and attach EEO programs within each manager's or supervisor's an EEOC FORM 715- area or responsibility. 01 PART H to the 

agency's status 

report 

 Measures Yes No N/A 

Are regular (monthly/quarterly/semi-annually) EEO updates provided to X management/supervisory officials by EEO program officials? 

Do EEO program officials coordinate the development and implementation of EEO 

Plans with all appropriate agency managers to include Agency Counsel, Human X 

Resource Officials, Finance, and the Chief information Officer? 

For all unmet Measure has been Compliance Indicator measures, provide a met The Human Resources Director and the EEO Director brief explanation in 

meet regularly to assess whether personnel programs, the space below or 

policies, and procedures are in conformity with complete and attach 

instructions contained in EEOC management directives. an EEOC FORM 715-

 Measures [see 29 CFR § 1614.102(b)(3)] 01 PART H to the 

agency's status 

report 

Yes No N/A 

Have time-tables or schedules been established for the agency to review its Merit 

Promotion Program Policy and Procedures for systemic barriers that may be X 

impeding full participation in promotion opportunities by all groups? 

Have time-tables or schedules been established for the agency to review its 

Employee Recognition Awards Program and Procedures for systemic barriers that X 

may be impeding full participation in the program by all groups? 

Have time-tables or schedules been established for the agency to review its 

Employee Development/Training Programs for systemic barriers that may be X 

impeding full participation in training opportunities by all groups? 

For all unmet Measure has been Compliance Indicator measures, provide a met brief explanation in 

When findings of discrimination are made, the agency the space below or 

explores whether or not disciplinary actions should be complete and attach 

taken. an EEOC FORM 715-

 Measures 01 PART H to the 

agency's status 

report 

Yes No N/A 

Does the agency have a disciplinary policy and/or a table of penalties that covers X employees found to have committed discrimination? 

16 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

Have all employees, supervisors, and managers been informed as to the penalties 

for being found to perpetrate discriminatory behavior or for taking personnel actions 

based upon a prohibited basis? 

X 

Has the agency, when appropriate, disciplined or sanctioned managers/supervisors 

or employees found to have discriminated over the past two years? X There were no findings of 

discrimination in FY 

2016 or FY 2017 

If so, cite number found to have discriminated and list penalty /disciplinary action 

Does the agency promptly (within the established time frame) comply with EEOC, 

Merit Systems Protection Board, Federal Labor Relations Authority, labor 

arbitrators, and District Court orders? 

X 

Does the agency review disability accommodation decisions/actions to ensure 

compliance with its written procedures and analyze the information tracked for X 

trends, problems, etc.?? 

17 
I 

Essential Element D: PROACTIVE PREVENTION 

Requires that the agency head makes early efforts to prevent discriminatory actions and eliminate barriers to equal

employment opportunity in the workplace. 

 For period covering October 1, 2016 to September 30, 2017 Department of Transportation/DOT Federal

Highway Administration 

Compliance Indicator

 Measures 

Analyses to identify and remove unnecessary barriers to

employment are conducted throughout the year. 

Measure has been 

met 

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 

Do senior managers meet with and assist the EEO Director and/or other EEO 

Program Officials in the identification of barriers that may be impeding the 

realization of equal employment opportunity? 

X 

When barriers are identified, do senior managers develop and implement, with the 

assistance of the agency EEO office, agency EEO Action Plans to eliminate said 

barriers? 

X 

Do senior managers successfully implement EEO Action Plans and incorporate the 

EEO Action Plan Objectives into agency strategic plans? X 

Are trend analyses of workforce profiles conducted by race, national origin, sex and 

disability? X 

Are trend analyses of the workforce's major occupations conducted by race, 

national origin, sex and disability? X 

Are trends analyses of the workforce's grade level distribution conducted by race, 

national origin, sex and disability? X 

Are trend analyses of the workforce's compensation and reward system conducted 

by race, national origin, sex and disability? X . 

Are trend analyses of the effects of management/personnel policies, procedures 

and practices conducted by race, national origin, sex and disability? X 

Compliance Indicator

 Measures 

The use of Alternative Dispute Resolution (ADR) is

encouraged by senior management. 

Measure has been 

met 

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 

Are all employees encouraged to use ADR? X 

Is the participation of supervisors and managers in the ADR process required? X 

Yes 

Yes 

18 
I 

Essential Element E: EFFICIENCY 

Requires that the agency head ensure that there are effective systems in place for evaluating the impact and

effectiveness of the agency's EEO Programs as well as an efficient and fair dispute resolution process. 

Department of Transportation/DOT Federal For period covering October 1, 2016 to September 30, 2017 Highway Administration 

For all unmet Measure has been 

Measure has been 

Compliance Indicator 

The agency has sufficient staffing, funding, and authority

to achieve the elimination of identified barriers. 

met measures, provide a

brief explanation in

the space below or

complete and attach

an EEOC FORM 715-

 Measures Yes No N/A 01 PART H to the 

agency's status 

report 

Does the EEO Office employ personnel with adequate training and experience to 

conduct the analyses required by MD-715 and these instructions? X 

Has the agency implemented an adequate data collection and analysis systems that 

permit tracking of the information required by MD-715 and these instructions? X 

Have sufficient resources been provided to conduct effective audits of field facilities' 

efforts to achieve a model EEO program and eliminate discrimination under Title VII 

and the Rehabilitation Act? 

X 

Is there a designated agency official or other mechanism in place to coordinate or 

assist with processing requests for disability accommodations in all major 

components of the agency? 

X 

Are 90% of accommodation requests processed within the time frame set forth in 

the agency procedures for reasonable accommodation? X 

For all unmet 

Compliance Indicator measures, provide a met brief explanation in 

The agency has an effective complaint tracking and the space below or 

monitoring system in place to increase the effectiveness complete and attach 

of the agency's EEO Programs. an EEOC FORM 715-

 Measures 01 PART H to the 

agency's status 

report 

Yes No N/A 

Does the agency use a complaint tracking and monitoring system that allows 

identification of the location, and status of complaints and length of time elapsed at X 

each stage of the agency's complaint resolution process? 

Does the agency's tracking system identify the issues and bases of the complaints, 

the aggrieved individuals/complainants, the involved management officials and X 

other information to analyze complaint activity and trends? 

Does the agency hold contractors accountable for delay in counseling and The Departmental X investigation processing times? Office of Civil Rights 

processes 

contract investigation 

s.FHWA has no 

contract EEO 

counselors. 

If yes, briefly describe how: 

19 
I 

Does the agency monitor and ensure that new investigators, counselors, including 

contract and collateral duty investigators, receive the 32 hours of training required in 

accordance with EEO Management Directive MD-110? 

FHWA does so with 

regard to EEO 

counselors.  The 

Departmental Office 

of Civil Rights is 

responsible for 

monitoring and 

training of 

investigators. FHWA 

has no investigators. 

The agency has sufficient staffing, funding and authority

to comply with the time frames in accordance with the

EEOC (29 C.F.R. Part 1614) regulations for processing

EEO complaints of employment discrimination. 

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 

Does the agency provide timely EEO counseling within 30 days of the initial 

request or within an agreed upon extension in writing, up to 60 days? 

Does the agency provide an aggrieved person with written notification of his/her 

rights and responsibilities in the EEO process in a timely fashion? 

FHWA does not 

manage the formal 

EEO complaint 

process. The 

Departmental Office 

of Civil Rights within 

the U.S. DOT owrks 

with contractors to 

complete 

investigation of 

formal EEO 

complaints. 

Does the agency monitor and ensure that experienced counselors, investigators, including 

contract and collateral duty investigators, receive the 8 hours of refresher training required on 

an annual basis in accordance with EEO Management Directive MD-110? 

FHWA does so wiht 

regard to EEO 

counselors. The 

Departmental Office 

of civil Rights is 

responsible for 

monitoring and 

training of 

investigators. FHWA 

has no investigators. 

 For period covering October 1, 2016 to September 30, 2017 Department of Transportation/DOT Federal

Highway Administration 

X 

Compliance Indicator

 Measures 

Measure has been 

met 

No N/A 

Are benchmarks in place that compare the agency's discrimination complaint 

processes with 29 C.F.R. Part 1614? X 

X 

X 

Does the agency complete the investigations within the applicable prescribed 

time frame? X 

Yes 

X 

20 
I For period covering October 1, 2016 to September 30, 2017 Department of Transportation/DOT Federal

Highway Administration 

When a complainant requests a final agency decision, does the agency issue 

the decision within 60 days of the request? X FHWA does not manage the formal 

EEO complaint 

process.  The 

Departmental Office 

of Civil Rights issues 

the final agency 

decision. 

When a complainant requests a hearing, does the agency immediately upon 

receipt of the request from the EEOC AJ forward the investigative file to the 

EEOC Hearing Office? 

X 

FHWA does not 

manage the formal 

EEO complaint 

process.  The 

Departmental Office 

of Civil Rights issues 

the final agency 

decision 

When a settlement agreement is entered into, does the agency timely complete 

any obligations provided for in such agreements? X 

Does the agency ensure timely compliance with EEOC AJ decisions which are 

not the subject of an appeal by the agency? X 

Compliance Indicator

 Measures 

There is an efficient and fair dispute resolution process

and effective systems for evaluating the impact and

effectiveness of the agency's EEO complaint processing 

program. 

Measure has been 

met 

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 

In accordance with 29 C.F.R. §1614.102(b), has the agency established an ADR 

Program during the pre-complaint and formal complaint stages of the EEO process? X The Departmental Office of Civil Rights 

Manages this ADR 

program. 

Does the agency require all managers and supervisors to receive ADR training in 

accordance with EEOC (29 C.F.R. Part 1614) regulations, with emphasis on the 

federal government's interest in encouraging mutual resolution of disputes and the 

benefits associated with utilizing ADR? 

X 

Managers and 

Supervisors are 

briefed on ADR, 

when applicable on a 

case by case basis. 

After the agency has offered ADR and the complainant has elected to participate in 

ADR, are the managers required to participate? X 

Yes 

Does the agency ensure that the responsible management official directly involved 

in the dispute does not have settlement authority? X The responsible 

management official 

directly invovled in 

the dispute does not 

have settlement 

authority.  A 

separate settlement 

official is appointed 

and has settlement 

authority. 

Measure has been Compliance Indicator met 

21 
 For period covering October 1, 2016 to September 30, 2017 Department of Transportation/DOT Federal

Highway Administration

 Measures 

The agency has effective systems in place for

maintaining and evaluating the impact and effectiveness

of its EEO programs. 

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 

Does the agency have a system of management controls in place to ensure the 

timely, accurate, complete and consistent reporting of EEO complaint data to the X 

Does the agency provide reasonable resources for the EEO complaint process to 

ensure efficient and successful operation in accordance with 29 C.F.R. § 1614.102 X 

Does the agency EEO office have management controls in place to monitor and 

ensure that the data received from Human Resources is accurate, timely received, 

and contains all the required data elements for submitting annual reports to the 

EEOC? 

X 

Do the agency's EEO programs address all of the laws enforced by the EEOC? X 

Does the agency identify and monitor significant trends in complaint processing to 

determine whether the agency is meeting its obligations under Title VII and the 

Rehabilitation Act? 

X 

Does the agency track recruitment efforts and analyze efforts to identify potential 

barriers in accordance with MD-715 standards? X 

Does the agency consult with other agencies of similar size on the effectiveness of 

their EEO programs to identify best practices and share ideas? X 

Compliance Indicator

 Measures 

The agency ensures that the investigation and

adjudication function of its complaint resolution process

are separate from its legal defense arm of agency or

other offices with conflicting or competing interests. 

Measure has been 

met 

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 

Are legal sufficiency reviews of EEO matters handled by a functional unit that is 

separate and apart from the unit which handles agency representation in EEO X Legal sufficiency reviews are handled 

at the Departmental 

level. 

Does the agency discrimination complaint process ensure a neutral adjudication 

function? X This is addressed at the Departmental 

level. 

If applicable, are processing time frames incorporated for the legal counsel's 

sufficiency review for timely processing of complaints? X This is addresed at the Departmental 

level. 

Yes 

Yes 

22 
I 

Essential Element F: RESPONSIVENESS AND LEGAL COMPLIANCE 

This element requires that federal agencies are in full compliance with EEO statutes and EEOC regulations, policy

guidance, and other written instructions. 

 For period covering October 1, 2016 to September 30, 2017 Department of Transportation/DOT Federal

Highway Administration 

Compliance Indicator

 Measures 

Agency personnel are accountable for timely compliance

with orders issued by EEOC Administrative Judges. 

Measure has been 

met 

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 

Does the agency have a system of management control to ensure that agency 

officials timely comply with any orders or directives issued by EEOC Administrative X 

Compliance Indicator

 Measures 

The agency's system of management controls ensures

that the agency timely completes all ordered corrective

action and submits its compliance report to EEOC within

30 days of such completion. 

Measure has been 

met 

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 

Does the agency have control over the payroll processing function of the agency? If 

Yes, answer the two questions below. X 

Are there steps in place to guarantee responsive, timely, and predictable 

processing of ordered monetary relief? X 

Are procedures in place to promptly process other forms of ordered relief? X 

Compliance Indicator

 Measures 

The agency's system of management controls ensures

that the agency timely completes all ordered corrective

action and submits its compliance report to EEOC within

30 days of such completion. 

Measure has been 

met 

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 

Is compliance with EEOC orders encompassed in the performance standards of any 

agency employees? X 

Yes 

Yes 

Yes 

23 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

If so, please identify the employees by title in the comments section, and state 

how performance is measured. 

Compliance with certain types of EEOC 

orders (e.g., acceptance of cases, 

investigations, FADs) occurs at the 

Departmental level so is not the subject 

of FHWA performance standards.  All 

managers, supervisors, and team 

leaders within FHWA have a 

performance element that includes a 

requirement to “take[s] timely corrective 

actions to ensure a workplace that is free 

from all forms of discrimination, 

harassment, and retaliation”.  Many 

FHWA attorneys who litigate 

employment law cases also have a 

requirement in their performance 

standards that they “assist in the 

implementation of court orders, 

decisions, and settlement agreements in 

a timely manner that allows for 

completion of the requirements of those 

documents on or before the deadlines 

established therein.” 

Is the unit charged with the responsibility for compliance with EEOC orders located 

in the EEO office? X The Departmental EEO office is 

responsible for 

compliance with 

orders regarding 

issues such as 

acceptance of cases, 

FADs, and 

investigations.  Other 

compliance (such as 

making payments) 

may reside in other 

offices depending on 

the content of the 

order.  FHWA 

counsel’s office 

informs these offices 

of the compliance 

requirements and 

tracks compliance. 

If not, please identify the unit in which it is located, the number of employees in 

the unit, and their grade levels in the comments section. 

See responses to F.3.b. 

Have the involved employees received any formal training in EEO compliance? X 

Does the agency promptly provide to the EEOC the following documentation for 

completing compliance: 

Attorney Fees: Copy of check issued for attorney fees and /or a narrative 

statement by an appropriate agency official, or agency payment order dating the 

dollar amount of attorney fees paid? 

X 

Awards: A narrative statement by an appropriate agency official stating the 

dollar amount and the criteria used to calculate the award? X 

Back Pay and Interest: Computer print-outs or payroll documents outlining gross 

back pay and interest, copy of any checks issued, narrative statement by an 

appropriate agency official of total monies paid? 

X 

24 
I Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

Compensatory Damages: The final agency decision and evidence of payment, if 

made? X 

Training: Attendance roster at training session(s) or a narrative statement by an 

appropriate agency official confirming that specific persons or groups of persons 

attended training on a date certain? 

X 

Personnel Actions (e.g., Reinstatement, Promotion, Hiring, Reassignment): 

Copies of SF-50s X 

Posting of Notice of Violation: Original signed and dated notice reflecting the 

dates that the notice was posted. A copy of the notice will suffice if the original is 

not available. 

X 

Supplemental Investigation: 1. Copy of letter to complainant acknowledging 

receipt from EEOC of remanded case. 2. Copy of letter to complainant 

transmitting the Report of Investigation (not the ROI itself unless specified). 3. 

Copy of request for a hearing (complainant's request or agency's transmittal 

letter). 

X 

This is handled at 

the Departmental 

level. 

Final Agency Decision (FAD): FAD or copy of the complainant's request for a 

hearing. X This is handled at 

the Departmental 

level.. 

Restoration of Leave: Print-out or statement identifying the amount of leave 

restored, if applicable. If not, an explanation or statement. X 

Civil Actions: A complete copy of the civil action complaint demonstrating same 

issues raised as in compliance matter. X 

Settlement Agreements: Signed and dated agreement with specific dollar 

amounts, if applicable. Also, appropriate documentation of relief is provided. X 

Footnotes: 

1. See 29 C.F.R. § 1614.102. 

2. When an agency makes modifications to its procedures, the procedures must be resubmitted to the Commission. See EEOC 

Policy Guidance on Executive Order 13164: Establishing Procedures to Facilitate the Provision of Reasonable Accommodation 

(10/20/00), Question 28 

25 
I 

EEOC FORM 

715-01 

PART H-1 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

 STATEMENT of

 MODEL PROGRAM

 ESSENTIAL ELEMENT

 DEFICIENCY: 

The agency has not trained all employees (supervisory and non-supervisory) on DOT’s 

anti-harassment policies. The agency has not trained all employees (supervisory and nonsupervisory) on DOT’s anti-harassment policies.

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

 RESPONSIBLE OFFICIAL: Associate Administrator for Civil Rights-Irene Rico 

DATE OBJECTIVE INITIATED: 1201/2016

 TARGET DATE FOR

 COMPLETION OF OBJECTIVE: 12/01/2016

 PLANNED ACTIVITIES TOWARD

 COMPLETION OF OBJECTIVE: 

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

TARGET DATE: 09/30/2017 

Present webinars or web-based sessions to be delivered and/or offered to managers, supervisors and employees. 

TARGET DATE: 0/30/2017

 REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

 • The FHWA appointed an anti-harassment coordinator and implemented a pilot anti-harassment program in the later part of 

FY 17. The designated Coordinator for FHWA is Program Analyst, Pamela Woodruff with oversight by Irene Rico, Associate 

Administrator for Civil Rights.  Mandatory anti-harassment training was delivered both in person and via webinar.  FHWA 

developed a memorandum of the Pilot Anti-Harassment Coordination Process along with an approved Anti-Harassment Policy 

Statement.

 • Out of the 2735* employees at FHWA, 2485 completed the training.  The trainings took place on the following dates:

 • In person session HQ-06/01/17

 • Webinar 06/14/17

 • In person session Connecticut Division Office-06/28/17

 • Webinar-July

 • In person session Central Federal Lands 07/17/17

 • Webinar 07/12/17

 • Webinar-07/26/17

 • In person session- NY Division 08/08/17 

*2735 employees was the total number of employees at the initiation of the Anti-Harassment training session when it launched in 

June 2017. Additionally, FHWA Office of Civil Rights conducted annual harassment training in FY 2017.  These mandatory 

training sessions will continue each FY that follows, via a series of webinars and in person sessions. Proactive Prevention is the 

best tool to eliminate harassment in the workplace. Therefore, FHWA’s training focuses on prevention and employee involvement 

in creating a civil and inclusive culture within the workplace. FHWA is currently are testing its interim/pilot anti-harassment 

program, and will evaluate this program by the end of FY 2018. It is expected in FY 2019 that FHWA will release a revised policy 

that will include all of the EEOC’s requested elements.    

26 
I 

EEOC FORM 

715-01 

PART H-2 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

 STATEMENT of

 MODEL PROGRAM

 ESSENTIAL ELEMENT

 DEFICIENCY: 

Agency does not conduct trend analysis on workforce data. The FHWA has not completed 

a 3-year trend analyses for the workforce compensation and reward system by race, 

national origin, sex, and disability. 

 OBJECTIVE: To conduct a trend analyses for workforce compensation and reward system by race, 

national origin, sex, and disability.

 RESPONSIBLE OFFICIAL: Acting Director of Human Resources - David Lewis 

DATE OBJECTIVE INITIATED: 1252005

 TARGET DATE FOR

 COMPLETION OF OBJECTIVE: 09/30/2017

 PLANNED ACTIVITIES TOWARD

 COMPLETION OF OBJECTIVE: 

HCR in partnership with HR will conduct an annual barrier analyses by race, national origin and sex on workforce compensation 

and awards for the last 3 to 5 years  

TARGET DATE: 09/30/2017 

HCR in partnership with HR will conduct an annual trend analyses by disability on workforce compensation and awards for the 

last 3 to 5 years 

TARGET DATE: 09/30/2017 

 REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

The FHWA completed its “At-A-Glance” workforce analysis report to FHWA employees.  This workforce analysis was presented 

as a snapshot of the agency’s workforce by Gender, Ethnicity, Disability, Grade Dispersion, Awards and Recognition. FHWA will 

continue to monitor and conduct an annual trend analyses by race, national origin and sex on workforce compensation and 

awards.   The Office of Human Resources conducted a review of fiscal year 2016 (FY16) Performance-based Awards, WithinGrade Increases, Developmental Assignments, and Performance-based Ratings, for all General Schedule (GS) employees. As 

part of our commitment to maintaining a diverse workforce, we conduct this review to ensure that these programs don’t create 

barriers based on gender, race and national origin (RNO), and disability. This report provides diversity information that may be 

used for needs assessment, program planning, program evaluation, and policy development activities. Based on the review, 

there were a few significant findings from the analysis conducted for FY16 Performance- based awards, Within-grade increases, 

Developmental assignments, and Performance ratings.  Overall females saw a slightly significant increase, excluding 

Performance-Based Awards. Overall, those that are classified as White still receive the highest amount of Performance-based 

Awards, Within-Grade Increases, Developmental Assignments, and Performance-based Ratings. However, the same 

demographic has also seen a slight gradual decrease over the fiscal years, as the amounts for other races have increased. 

Those classified as Hispanic or Latino saw a 5% increase in Developmental Assignments. This report included detail breakdown 

of gender, RNO, disability, grade and major occupation for Performance-based Awards, Within-Grade Increases, Developmental 

Assignments, and Performance-based Ratings, for all GS employees. 

27 
I 

EEOC FORM 

715-01 

PART H-3 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

 STATEMENT of Tracking recruitment efforts and using this data to identify potential barriers in accordance 

 MODEL PROGRAM with MD-715 standards. The FHWA does not track the effectiveness of our targeted 

 ESSENTIAL ELEMENT outreach recruitment efforts and analyze resulting data to identify potential barriers in 

 DEFICIENCY: accordance with MD-715 standards.  

 OBJECTIVE: To track and analyze the effectiveness of our targeted recruitment outreach efforts to 

determine whether the FHWA is yielding a sufficient number of applications from the 

targeted recruitment activities conducted throughout the year

 RESPONSIBLE OFFICIAL: Associate Administrator for Civil Rights-Irene Rico; Acting Director of Human Resources -

David Lewis 

DATE OBJECTIVE INITIATED: 12/15/2011

 TARGET DATE FOR

 COMPLETION OF OBJECTIVE: 09/30/2019

 PLANNED ACTIVITIES TOWARD

 COMPLETION OF OBJECTIVE: 

FHWA will work to identify the best approach to gathering and tracking data on recruitment resources 

TARGET DATE: 09/17/2017 

Analyze Data 

TARGET DATE: 09/30/2017

 REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

The Agency experienced a hiring freeze from January 2017, and thus recruitment efforts were not as expected for FY17. A 

modified plan will be developed with the target date of 09/30/2019 so that multiple year trend analyses can be performed. 

Recruitment activities will continue to be monitored for hiring trends for FY 18/19. 

28 
I 

EEOC FORM 

715-01 

PART H-4 

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

 STATEMENT of

 MODEL PROGRAM

 ESSENTIAL ELEMENT

 DEFICIENCY: 

Reduce the number of untimely EEO Counselings. In a minority of cases, the Agency has 

not provided timely EEO counseling within 30 days of the initial request or within an agreed 

upon extension in writing, up to 60 days.

 OBJECTIVE: To ensure all pre-complaints are processed within the regulatory timeframes pursuant to 

Management 110 and 29 CFR 1614.

 RESPONSIBLE OFFICIAL: Associate Administrator for Civil Rights-Irene Rico 

DATE OBJECTIVE INITIATED: 03/09/2018

 TARGET DATE FOR

 COMPLETION OF OBJECTIVE: 09/30/2018

 PLANNED ACTIVITIES TOWARD

 COMPLETION OF OBJECTIVE: 

Program Manager will require EEO counselors to submit requests for extension three days in advance of the counseling ending 

date to the Program Manager.  

TARGET DATE: 04/30/2018 

Program Manager will monitor and track each pre-complaint filed and follow-up with EEO counselors via phone or email when 

the case is nearing its respective counseling end date (30th, 60th or 90th)).   

TARGET DATE: 05/31/2018 

Program Manager will hold bi-monthly EEO counselor’s meetings to provide training, technical assistant and address any 

concerns with processes or any concerns EEO counselors may have regarding their counseling responsibilities. 

TARGET DATE: 05/31/2018

 REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FHWA will report on the accomplishments in FY 2018 MD -715 report. 

29 
I 

EEOC FORM 

715-01

PART H-5

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

Department of Transportation/DOT Federal

Highway Administration For period covering October 1, 2016 to September 30, 2017 

 STATEMENT of

 MODEL PROGRAM

 ESSENTIAL ELEMENT

 DEFICIENCY: 

Anti-Harassment Policy Statement and Procedures The FHWA does not have AntiHarassment procedures to complement its current Anti-Harassment policy. The FHWA is 

developing its procedures and planning to address this deficiency in FY 2019.  

 OBJECTIVE: Revise current Anti-Harassment policy statement to bring it in compliance with EEOC 

requirements.

 RESPONSIBLE OFFICIAL: Associate Administrator for Civil Rights-Irene Rico 

DATE OBJECTIVE INITIATED: 03/30/2018

 TARGET DATE FOR

 COMPLETION OF OBJECTIVE: 09/30/2019

 PLANNED ACTIVITIES TOWARD

 COMPLETION OF OBJECTIVE: 

Currently the FHWA is piloting an anti-harassment coordination process.  Based on the outcome of that pilot, FHWA will be 

finalizing its procedures for addressing harassment in the workplace, including the decision-maker on allegations of harassment.

 The procedures we adopt will be articulated in a new signed Anti-Harassment Policy Statement.    

TARGET DATE: 09/30/2019

 REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE 

FHWA will report out its accomplishments for this deficiency in its report for FY 2019. 

30 
Department of Transportation/DOT Federal

 STATEMENT OF CONDITION THAT WAS A TRIGGER FOR White Women, Hispanic men and women, American Indian or A POTENTIAL BARRIER: Alaska Native women and men, men and women reporting 

two or more races, and PWTD have lower than expected Provide a brief narrative describing the condition at issue. participation rates within FHWA?s workforce.Workforce Data 

TablesA//B1, A/B6. A/B7, A/B9, A/B11 How was the condition recognized as a potential barrier? 

 BARRIER ANALYSIS:

 Provide a description of the steps taken and data analyzed to

 determine cause of the condition. 

FHWA has a low participation rate for the groups identified 

below as compared with the FY 2010 Civilian Labor 

Workforce.

• Women

• Hispanic Females

• White Females

• Native Hawaiian or Other

• Pacific Islander Females

• American Indian or Alaska Native Females

• Two or More Races Males

 STATEMENT OF IDENTIFIED BARRIER: White Women, Hispanic men and women, American Indian or 

Alaska Native women and men, men and women reporting Provide a succinct statement of the agency policy, procedure two or more races, have lower than expected participation or practice that has been determined to be the barrier of the rates within FHWA's workforce. undesired condition. 

 OBJECTIVE: FHWA will establish new outreach efforts to recruit qualified 

female applicants and applicants from groups with lower than 

 State the alternative or revised agency policy, procedure or expected participation rates. FHWA will leverage its resources 

 practice to be implemented to correct the undesired to increase recruitment efforts, through the 2018-2019 

 condition. Strategic Plan.

 TARGET DATE FOR COMPLETION OF OBJECTIVE: 09/30/2020 

EEOC FORM 

715-01

PART I 

EEO Plan To Eliminate Identified Barrier 

-1

 PLANNED ACTIVITIES TOWARD

 COMPLETION OF OBJECTIVE:

 TARGET DATE

 (Must be specific) 

Continue to conduct Barrier analysis and various trend analyses on workforce 

profile data, major occupations, grade distribution, the workforce 

compensation reward system, and management/personnel policies, practices 

and procedures. 

 REPORT OF ACCOMPLISHMENTS and MODIFICATIONS TO OBJECTIVE

I 

31 

715-01

PART I -1

U.S. Equal Employment Opportunity Commission

FEDERAL AGENCY ANNUAL 

EEO PROGRAM STATUS REPORT 

For period covering October 1, 2016 to September 30, 2017 

EEOC FORM 

Associate Administrator for Civil Rights- Irene Rico ;Acting 

Director of Human Resources-David Lewis

03/19/2018

 RESPONSIBLE OFFICIAL: 

 DATE OBJECTIVE INITIATED: 

Continue to implement the Hispanic Recruitment Plan to attract, recruit, 

develop and retain Hispanic representation. 

09/30/2019 

09/30/2019
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 C.F.R. § 1614.203(d)(7)) require agencies to establish specific 

numerical goals for increasing the participation of persons with reportable and targeted 

disabilities in the federal government. 

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

involving PWD by grade level cluster in the permanent workforce? If "yes",

describe the trigger(s) in the text box.

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

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

The percentage of PWD in the GS 11 to SES cluster was 8.53% in FY 2017, which 

falls below the goal of 12%.   

* For GS employees, please use two clusters: GS-1 to GS-10 and GS-11 to SES,

as set forth in 29 C.F.R. § 1614.203(d)(7). For all other pay plans, please use the

approximate grade clusters that are above or below GS-11 Step 1 in the

Washington, DC metropolitan region.

2. Using the goal of 2% as the benchmark, does your agency have a trigger

involving PWTD by grade level cluster in the permanent workforce? If "yes",

describe the trigger(s) in the text box.

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

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

The percentage of PWTD in the GS 11 to SES was .67% in FY 2017, which falls 

below the goal of 2%.  

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

managers and/or recruiters.

The FHWA Office of Human Resources is committed and has communicated to the 

hiring managers the importance of increasing the number of individuals with targeted 

32 
disabilities.  We notified hiring managers of the established hiring goals for FY2017 for 

people with disabilities (targeted and non-targeted). We will continue to track progress 

closely and re-evaluate hiring and retention goals on a quarterly basis. 

People with Disabilities activities are monitored, reviewed and evaluated throughout 

the fiscal year by the Office of Human Resources to ensure its success and to 

promote and communicate diversity and inclusion efforts in FHWA.  The information is 

communicated in Headquarters and field offices through Human Resources 

Specialists; workforce statistical data and monthly reports to hiring managers and 

supervisors on the status of people with disabilities hires, promotion and retention; 

and, FHWA’s website and Intranet to ensure transparency. 

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 

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. 

Disability Program Task 

# of FTE Staff by

Employment Status Responsible Official

(Name, Title, Office, Email) 

Full Time Part Time Collateral Duty 

Processing applications 

from PWD and PWTD 

1 0 0 Eleni Triantafell, Human 

Resources Specialist 

Answering questions from 

the public about hiring 

authorities that take 

disability into account 

1 0 0 Eleni Triantafell, Human 

Resources Specialist 

Processing reasonable 

accommodation requests 

from applicants and 

employees 

2 0 1 Eleni Triantafell, Human 

Resources Specialist 

Kirsten Poston, Disability 

Resource Manager 

Chris Lankford, Program 

Analyst 

Section 508 Compliance 1 0 0 Stephanie Jackson, Project 

Manager 

Architectural Barriers Act 

Compliance 

1 0 0 Jeffrey Baxter, Associate 

Director of Facilities 

33 
Disability Program Task 

# of FTE Staff by

Employment Status Responsible Official

(Name, Title, Office, Email) 

Full Time Part Time Collateral Duty 

Special Emphasis Program 

for PWD and PWTD 

1 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(s) that disability program staff have received. If “no”, describe the 

training(s) planned for the upcoming year. 

Answer: Yes 

For recruiting and hiring people with targeted disabilities and non-targeted disabilities, 

the disability program staff in the FHWA Office of Human Resources received training 

related to Human Resources in the areas of Qualifications Analysis; Hiring Flexibilities 

to include Schedule A and Veterans; Using HR Analysis; Federal Staffing Placement; 

Federal Pay Setting; Recruitment Sourcing; Employment Branding; and Writing 

Effective Job Announcements. 

For Reasonable Accommodations, the disability program staff in the Office of Civil 

Rights received training in on the Reasonable Accommodations process at the 

EEOC’s EXCEL 2017 Conference and the 2017 Federal Dispute Resolution 

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 

In FY 2017, the FHWA Office of Human Resources received funding for internship 

programs for college students and recent graduates, procuring recruitment and 

outreach events, and placing advertisements with various diverse societies and 

organizations as vacancies become available and when funding for advertisements is 

available. 

Leadership development, management, and supervisory training programs were 

funded.  The programs help candidates prepare for promotion and leadership 

opportunities. 

Section III: Plan to Recruit and Hire Individuals with Disabilities 

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

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

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

A. PLAN TO IDENTIFY JOB APPLICANTS WITH DISABILITIES 

34 
1. Describe the programs and resources the agency uses to identify job 

applicants with disabilities, including individuals with targeted disabilities. 

In FY 2017, the FHWA Office of Human Resources attended targeted recruitment and 

outreach events designed to network and meet job applicants with disabilities. 

Contact is maintained with disability organizations and colleges with disability offices 

to provide them with information on employment opportunities, internship programs 

and with assistance in recruitment.  These organizations and colleges have helped us 

build or post job announcements on their free recruitment sites so they are more 

visible in those specific communities. 

FHWA will continue using the following recruitment resources:  OPM’s Shared List of 

People with Disabilities; the Workforce Recruitment Program (WRP) database; State 

and local vocational rehabilitation agencies and employment offices; the Department 

of Veterans Affairs, Wounded Warrior Office and Vets 2 Feds; Military installations 

and transition offices; US Department of Labor, Employer Assistance and Resources 

Network (EARN); Department of Defense, Operation Warfighter Program; educational 

institutions, colleges and universities, and career fairs; and, other organizations whose 

primary focus is working to employ people with disabilities.  In addition, the FHWA 

Disability Program website includes a comprehensive listing of veteran’s and persons 

with disabilities organizations. 

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 Human Resources Specialists advises managers on the hiring process for 

Schedule A, Excepted Service, Veterans Recruitment Appointment (VRA), and 30% 

or more Disabled Veterans appointments.  Vacancies that are advertised 

“government-wide” and “all sources” include a statement on PWD and consideration 

under special appointing authorities.  Eligibility criteria are addressed on open 

competitive vacancy announcements to educate those candidates unfamiliar with 

application procedures, forms, and requirements.  Applicants with disabilities who 

meet the job qualifications are referred to the hiring managers. 

Targeted Schedule A job announcements are sent to veteran and disability 

organizations, and colleges with disability offices to provide them with information on 

employment and internship opportunities.  

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 Human Resources Specialists works directly with hiring managers to 

use the non-competitive excepted service hiring authorities, including Schedule A. 

They consult with hiring managers on all phrases of the recruitment and hiring 

process.  The hiring manager may use a position description that is already completed 

or coordinates with the Human Resources Specialist to develop a functional position 

description.  The hiring manager will also need to consider the skills and abilities that 

35 
a candidate needs to fulfill the essential functions of the job.  Working with the hiring 

manager, the excepted service announcements are developed and forwarded to 

various professional organizations including veteran and disability organizations, 

colleges/universities, state and local vocational rehabilitation agencies and 

employment offices to broaden the applicant pool.  The Human Resources Specialist 

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 the qualified candidates, he/she decides if the applicant can perform the 

job duties and is a good fit for FHWA.  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 

FHWA Human Resources Specialists conducted webinars to the HR community and 

hiring managers on using non-competitive hiring strategies, including hiring veterans 

and PWD.  The Office of Human Resources will have additional training sessions for 

managers and supervisors on strategies for successful recruitment including the hiring 

process, the advancement and retention of PWD (e.g., Schedule A); and on disability 

awareness. 

Human Resources Specialists met with hiring managers at Headquarters and field 

program offices on the non-competitive hiring process and the hiring flexibilities.  At 

these briefing sessions, hiring managers were encouraged to promote and create job 

opportunities for applicants with disabilities at all grade levels, as well as promoting 

internship opportunities for applicants with disabilities.  They were also provided with 

information on how to conduct targeted outreach, ensure that the hiring process is 

accessible, ask effective questions during an interview, and have a successful 

onboarding process. 

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. 

FHWA has identified national and local disability employment organizations, colleges, 

as well as state service providers who can disseminate job postings.  These 

organizations, colleges, and state service providers contact PWD and PWTD 

regarding our job postings and help us identify potential candidates.  We maintain 

contact and continue to work with them through the recruitment process.  These 

contacts are valuable for our hiring success and deliver productive results. 

Additionally, FHWA participates in recruitment events across the country 

36 
through partnerships with Minority Serving Institutions and organizations such as 

Historically Black Colleges Universities, Hispanic-Serving Institutions, Hispanic 

Association of Colleges and Universities, and Hispanic/Latino Professionals 

Association to increase the diversity of the applicant pool. 

In FY 2017, FHWA attended 17 recruitment events at colleges, universities, academic 

institutions, and professional associations that support populations of diverse 

recruitment candidates.  The FHWA also attended two (2) special events for 

elementary and middle school students, and high school students to educate them on 

careers in transportation, related academic disciplines, internship programs, and the 

volunteer student program. 

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: Yes 

Among new hires in the permanent workforce no triggers exist for PWD (12.42%). 

Triggers exist for PWTD (1.86%), falls below the benchmark of 2% of PWTD. This 

workforce tables did not include the intra transfer within modes to FHWA. 

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. 

a. New Hires for MCO (PWD) Answer: Yes 

b. New Hires for MCO (PWTD) Answer: Yes 

In comparison to the qualified applicant pool benchmark, triggers for some of the 

MCOs exist as summarized below.  FHWA notes that the low number of selections for 

many of these MCOs creates a sample size where the trigger may not indicate a 

statistically valid indication that there is a difference between the number of selections 

expected and the number that occurred. 

Compared to the benchmarks, Triggers exist for PWD/PWTD in the following Mission 

Critical Occupations: 

0020 Community Planning (YES=PWD 4.28% qualified 0% selected, YES= PWTD 

1.97% qualified, 0% selected) 

0028 Environmental Protection Specialist (NO=PWD 2.89% qualified, 9.09% selected, 

YES=PWTD 1.73% qualified, 0% selected) 

05801 Financial Administration and Program (NO= PWD 7.02% qualified, 16.67% 

selected, YES= PWTD 2.89% qualitied, 0% selected) 

0505 Financial Management -No Positions Filled 

0802 Engineering Technician (YES=PWD 8.75% qualified, 0% selected, YES=PWTD 

7.50 % qualified, 0% selected) 

37 
0810 Civil Engineering (NO=PWD 1.93% qualified, 9.68% selected), YES=PWTD 

2.08% qualified, 0% selected) 

1170 Realty Series (NO=PWD 2.08% qualified, 20% selected, YES=PWTD 2.08% 

qualified, 0% selected) 

2101 Transportation Specialist (YES=3.37% qualified, 0% selected, YES=PWTD 

1.91% qualified, 0% selected) 

See Table B7 

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 missioncritical occupations (MCO)? If “yes”, please describe the triggers below. 

a. Qualified Applicants for MCO (PWD) Answer: Yes 

b. Qualified Applicants for MCO (PWTD) Answer: Yes 

In comparison to the relevant applicant pool benchmark, triggers for some of the 

MCO's exist as summarized below: 

0020 Community Planning YES=PWD (8.48% in pool, 0% qualified) YES= PWTD 

(.85% in pool, 0% qualified) 

0028 Environmental Protection Specialist YES=PWD (6.73% in pool, 0% qualified), 

No=PWTD (0% in pool, 0% qualified) 

05801 Financial Administration and Program YES= PWD (9.14% in pool, 

6.38% qualified),  No= PWTD  0%  in pool, 4.26% qualified) 

0505 Financial Management - NO - Did not fill any vacancies 

0802 Engineering Technician YES=PWD (12.37% in pool, 0 % qualified,) YES=PWTD 

(2.06% in pool, 0% qualified) 

0810 Civil Engineering  YES=PWD (6.16% in pool, 2.80% qualified), YES=PWTD 

(2.06% in pool, 0% qualified) 

1170 Realty Series YES=PWD (2.70% in the pool, 0% qualified)  No=PWTD (0% in 

the pool, 0% qualified) 

2101 Transportation Specialist  YES=(7.85% in the pool, 3.28% qualified) No=PWTD 

(2.01% in the pool, 2.69% qualified) 

See Table B9 

4. Using the qualified applicant pool as the benchmark, do triggers exist for PWD 

and/or PWTD among employees promoted to any of the mission-critical 

occupations (MCO)? If “yes”, please describe the triggers below. 

a. Promotions for MCO (PWD) Answer: No 

b. Promotions for MCO (PWTD) Answer: Yes 

In comparison to the qualified applicant pool benchmark, there were no triggers for 

PWD in any MCO).  Triggers for some of the MCOs exist for PWTD as summarized 

below: 

0020 Community Planning  NO=(0% qualified, 0% selected), YES= PWTD (0% 

qualified, 0% selected) 

0028 Environmental Protection Specialist NO=(0% qualified, 0% selected), YES= 

PWTD (0% qualified, 0% selected) 

38 
05801 Financial Administration and Program NO=(6.38% qualified, 16.67% selected), 

YES= PWTD (4.26% qualified, 0% selected) 

0505 Financial Management -NO Vacancies Filled 

0802 Engineering Technician NO=(0% qualified, 0% selected), YES= PWTD (0% 

qualified, 0% selected) 

0810 Civil Engineering NO=PWD 1.93% qualified, 9.68% selected), YES=PWTD 

2.08% qualified, 0% selected) 

1170 Realty Series NO=(0% qualified, 0% selected), YES= PWTD (0% qualified, 0% 

selected) 

2101 Transportation Specialist (No=3.28% qualified, 11.11% selected), NO=PWTD 

(2.69% qualified, 5.56% selected) 

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. 

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. 

B. CAREER DEVELOPMENT OPPORTUNITIES 

39 
1. Please describe the career development opportunities that the agency provides 

to its employees. 

FHWA encourages and provides training and career development opportunities for all 

employees, including PWD and PWTD.  Career development opportunities consist of 

internship programs, mentoring program, coaching program, training programs, and 

rotational assignment opportunities.  All employees are notified of developmental and 

training opportunities via the FHWA’s Temporary Developmental Assignment 

Clearinghouse, the Professional Development Program Clearinghouse, The Learning 

Highway, Career Advancement Webinar Series, Webinar Library, Training and 

Development email system, Employee Awareness Program and Training 

Management System.  All employees are encouraged to develop and maintain 

Individual Development Plans (IDPs), designed to identify training and competencies, 

and help their career advancement opportunities. 

2. 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 applicants and the applicant pool for selectees.) If "yes", 

describe the trigger(s) in the text box. 

a. Applicants (PWD) Answer: No 

b. Selections (PWD) Answer: No 

3. Do triggers exist for PWTD among the applicants and/or selectees for any of 

the career development programs identified? (The appropriate benchmarks are 

the relevant applicant pool for applicants and the applicant pool for selectees.) 

If "yes", describe the trigger(s) in the text box. 

a. Applicants (PWTD) Answer: No 

b. Selections (PWTD) Answer: No 

C. AWARDS 

40 
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: No 

b. Awards, Bonuses, & Incentives (PWTD) Answer: No 

2. Using the inclusion rate as the benchmark, does your agency have a trigger 

involving PWD and/or PWTD for quality step increases or performance-based 

pay increases? If "yes", please describe the trigger(s) in the text box. 

a. Pay Increases (PWD) Answer: No 

b. Pay Increases (PWTD) Answer: No 

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: No 

b. Other Types of Recognition (PWTD) Answer: No 

D. PROMOTIONS 

41 
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. 

a. SES 

i. Qualified Internal Applicants (PWD) Answer: No 

ii. Internal Selections (PWD) Answer: Yes 

b. Grade GS-15 

i.Qualified Internal Applicants (PWD) Answer: Yes 

ii. Internal Selections (PWD) Answer: No 

c. Grade GS-14 

i.Qualified Internal Applicants (PWD) Answer: Yes 

ii. Internal Selections (PWD) Answer: No 

d. Grade GS-13 

i.Qualified Internal Applicants (PWD) Answer: Yes 

ii. Internal Selections (PWD) Answer: No 

In comparison to the applicable benchmarks, there were triggers for PWD regarding 

each grade level, but in no instance was there a trigger for both qualified internal 

applicants and selectees. Trigger information is summarized below:

 Grade 

Relevant pool vs. qualified applicants 

SES  No (6.80% in pool, 11.76% qualified) 

GS- 15  Yes (6.90% in pool, 3.36% qualified) 

GS-14  Yes (7.0% in pool, 3.53% qualified) 

GS 13  Yes (10.45% in pool, 2.99% qualified) 

Qualified applicants vs. selected 

SES Yes (11.76 % qualified, 0% selected) 

GS -15  No (3.36% qualified, 6.67% selected) 

GS- 14  No (3.53% qualified, 4% selected) 

GS -13  No (2.99% qualified, 8.57% selected) 

See Also Table B11 

42 
2. Does your agency have a trigger involving PWTD among the qualified internal

applicants and/or selectees for promotions to the senior grade levels? (The 

appropriate benchmarks are the relevant applicant pool for qualified internal 

applicants and the qualified applicant pool for selectees.) For non-GS pay 

plans, please use the approximate senior grade levels. If "yes", describe the 

trigger(s) in the text box. 

a. SES 

i. Qualified Internal Applicants (PWTD) Answer: No 

ii. Internal Selections (PWTD) Answer: Yes 

b. Grade GS-15 

i.Qualified Internal Applicants (PWTD) Answer: No 

ii. Internal Selections (PWTD) Answer: No 

c. Grade GS-14 

i.Qualified Internal Applicants (PWTD) Answer: No 

ii. Internal Selections (PWTD) Answer: No 

d. Grade GS-13 

i.Qualified Internal Applicants (PWTD) Answer: No 

ii. Internal Selections (PWTD) Answer: Yes 

In comparison to the applicable benchmarks, there were triggers for PWTD for SES, 

GS-14, and GS-13, but not for GS-15.  In no instance was there a trigger for both 

qualified internal applicants and selectees. Trigger information is summarized . 

 Grade 

Relevant pool vs. qualified applicants 

SES  No (1.3% in pool, 11.76% qualified) 

GS-15  No (1.6% in pool, 2.52% qualified) 

GS-14  No (.80% in pool, 2.52% qualified) 

GS-13 No (1.26% in pool, 2.33% qualified) 

Qualified applicants vs. selected 

SES Yes (11.76% qualified, 0% selected) 

GS-15  No (2.52% qualified, 6.67% selected) 

GS-14  Yes (2.52% qualified, 2.35% selected) 

GS-13  Yes (2.33% qualified, 0% selected) 

See Also Table B11 

43 
3. Using the qualified applicant pool as the benchmark, does your agency have a 

trigger involving PWD among the new hires to the senior grade levels? For 

non-GS pay plans, please use the approximate senior grade levels. If "yes", 

describe the trigger(s) in the text box. 

a. New Hires to SES (PWD) Answer: No 

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

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

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

Insufficient data to complete at this time. 

4. Using the qualified applicant pool as the benchmark, does your agency have a 

trigger involving PWTD among the new hires to the senior grade levels? For 

non-GS pay plans, please use the approximate senior grade levels. If "yes", 

describe the trigger(s) in the text box. 

a. New Hires to SES (PWTD) Answer: No 

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

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

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

Insufficient data to complete at this time. 

5. Does your agency have a trigger involving PWD among the qualified internal

applicants and/or selectees for promotions to supervisory positions? (The 

appropriate benchmarks are the relevant applicant pool for qualified internal 

applicants and the qualified applicant pool for selectees.) If "yes", describe the 

trigger(s) in the text box. 

a. Executives 

i. Qualified Internal Applicants (PWD) Answer: No 

ii. Internal Selections (PWD) Answer: No 

b. Managers 

i.Qualified Internal Applicants (PWD) Answer: No 

ii. Internal Selections (PWD) Answer: No 

c. Supervisors 

i.Qualified Internal Applicants (PWD) Answer: No 

ii. Internal Selections (PWD) Answer: No 

44 
Insufficient data to complete at this time. 

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. 

a. Executives 

i. Qualified Internal Applicants (PWTD) Answer: No 

ii. Internal Selections (PWTD) Answer: No 

b. Managers 

i.Qualified Internal Applicants (PWTD) Answer: No 

ii. Internal Selections (PWTD) Answer: No 

c. Supervisors 

i.Qualified Internal Applicants (PWTD) Answer: No 

ii. Internal Selections (PWTD) Answer: No 

Insufficient data to complete at this time.  

7. Using the qualified applicant pool as the benchmark, does your agency have a 

trigger involving PWD among the selectees for new hires to supervisory 

positions? If "yes", describe the trigger(s) in the text box. 

a. New Hires for Executives (PWD) Answer: No 

b. New Hires for Managers (PWD) Answer: No 

c. New Hires for Supervisors (PWD) Answer: No 

Insufficient data to complete at this time. 

8. Using the qualified applicant pool as the benchmark, does your agency have a 

trigger involving PWTD among the selectees for new hires to supervisory 

positions? If "yes", describe the trigger(s) in the text box. 

a. New Hires for Executives (PWTD) Answer: No 

b. New Hires for Managers (PWTD) Answer: No 

c. New Hires for Supervisors (PWTD) Answer: No 

Insufficient data to complete at this time. 

45 
Section V: Plan to Improve Retention of Persons with Disabilities 

To be a model employer for persons with disabilities, agencies must have policies and 

programs in place to retain employees with disabilities. In this section, agencies should: (1) 

analyze workforce separation data to identify barriers retaining employees with disabilities; (2) 

describe efforts to ensure accessibility of technology and facilities; and (3) provide information 

on the reasonable accommodation program and workplace personal assistance services. 

A. VOLUNTARY AND INVOLUNTARY SEPARATIONS 

1. In this reporting period, did the agency convert all eligible Schedule A 

employees with a disability into the competitive service after two years of 

satisfactory service (5 C.F.R. § 213.3102(u)(6)(i))? If "no", please explain why 

the agency did not convert all eligible Schedule A employees. 

Answer: Yes 

FHWA had to delay the conversion of one eligible Schedule A employee with a 

disability into the competitive service after two years of satisfactory service due to FTE 

budget restriction and a hiring freeze.  After this delay, the employee was converted 

into the competitive service in FY 2018. 

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: No 

b. Involuntary Separations (PWD) Answer: No 

3. Using the inclusion rate as the benchmark, did the percentage of PWTD among 

voluntary and involuntary separations exceed that of persons without targeted 

disabilities? If "yes", describe the trigger below. 

a. Voluntary Separations (PWTD) Answer: No 

b. Involuntary Separations (PWTD) Answer: No 

4. If a trigger exists involving the separation rate of PWD and/or PWTD, please 

explain why they left the agency using exit interview results and other data 

sources. 

N/A 

B. ACCESSIBILITY OF TECHNOLOGY AND FACILITIES 

46 
Pursuant to 29 C.F.R. § 1614.203(d)(4), federal agencies are required to inform job applicants 

and employees of their rights under Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 

794(b)), concerning the accessibility of agency technology, and the Architectural Barriers Act of 

1968 (42 U.S.C. § 4151 – 4157), concerning the accessibility of agency facilities. In addition, 

agencies are required to inform individuals where to file complaints if other agencies are 

responsible for a violation. 

1. Please provide the internet address on the agency's public website for its 

notice explaining employees' and applicants' rights under Section 508 of the 

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

The internet address on the agency’s public website regarding Section 508 of the 

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

https://www.transportation.gov/accessibility.  Also, a helpful link, 

http://www.section508.gov, can be found on the agency’s public website. 

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 of 1968 is https://www.access-board.gov/guidelines-and-standards/buildings-andsites/about-the-aba-standards.  Another internet address is also available at: 

https://www.access-board.gov/guidelines-and-standards/buildings-and-sites. 

3. Describe any programs, policies, or practices that the agency has undertaken, 

or plans on undertaking over the next fiscal year, designed to improve 

accessibility of agency facilities and/or technology. 

The Office of Human Resources will continue to update the agency’s Disability 

Program website with appropriate links; update the Intranet on resume writing, 

interviewing, and coaching; use emails to assist in recruiting individuals with 

disabilities and to raise awareness.  This website is used to provide information and 

resources for managers in recruiting individuals with disabilities and disabled 

veterans.  Human Resources Specialists, managers, and supervisors are aware of 

special appointment authorities that can be used in the hiring of individuals with 

disabilities and veterans with disabilities. 

C. REASONABLE ACCOMMODATION PROGRAM 

47 
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.) 

According to the DOT Order 1011.1A the time frames for processing reasonable 

accommodation requests is 25 business days.  FHWA processes reasonable 

accommodation requests in accordance with the policy and requests are entered into 

the Department’s Reasonable Accommodation 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. 

The Departmental Office of Civil Rights prepared and issued a policy document, “DOT 

Order 1011.1A – Procedures for Processing Reasonable Accommodation Requests 

from Job Applicants and DOT Employees with Disabilities.”  This document includes 

procedures for processing reasonable accommodation requests for employees and 

job applicants with disabilities, and includes timely processing requests as well as 

providing timely approved accommodations. 

The U.S. Department of Transportation (DOT)’s Disability Resource Center (DRC) has 

a pool of interpreters and also has personal assistants on site daily for any applicants 

or employees with disabilities.  To assist OAs with providing reasonable 

accommodations to employees and job applicants, DRC provides services to the 

entire DOT.  The DRC is funded by the Working Capital Fund which ensures fair and 

consistent outcomes throughout DOT. 

Assistive Technology Training:  To ensure the employee’s success in using the 

identified product, training can also be provided by DRC.  This training is usually 

contracted with an outside vendor.  The vendor will be provided with the employee’s 

contact information and will contact the employee to schedule the training directly with 

the employee. 

DRC released an updated Version 2.0 of their Services Handbook in August, 2017. 

Highlights of the updated handbook include: 

•   Chapters and headings have been streamlined to ensure smooth navigation 

throughout the document. 

•   Section 4.6, “Sign Language Interpreting,” has been redone to reflect changes 

to procedures brought about by the new nationwide interpreting services contract that 

took effect April 1, 2017.  Procedures have been standardized nationwide, regardless 

of the location of services provided. 

•   A new Appendix has been added to include factors to consider when deciding 

whether to pay the salary for an employee’s own Personal Attendant while on travel. 

FHWA previously in 2016 provided a training Webinar to all managers and 

48 
supervisors on “Reasonable Accommodations – Performance/Conduct”. 

D. PERSONAL ASSISTANCE SERVICES ALLOWING EMPLOYEES TO 

PARTICIPATE IN THE WORKPLACE 

Pursuant to 29 C.F.R. § 1614.203(d)(5), federal agencies, as an aspect of affirmative action, 

are required to provide personal assistance services (PAS) to employees who need them 

because of a targeted disability, unless doing so would impose an undue hardship on the 

agency. 

Describe the effectiveness of the policies, procedures, or practices to implement the PAS 

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

timely providing approved services, conducting training for managers and supervisors, and 

monitoring PAS requests for trends. 

In the workplace, Personal Assistance Services (PAS) is provided as a reasonable 

accommodation; therefore, obtaining these services are handled in the same manner 

as follows:

 1. The employee requests PAS by informing either his supervisor, human 

resources personnel, designated decision maker, other suitable DOT representative 

that he or she requires assistance with daily life activities because of a medical 

condition/targeted disability.

 2. The employee and/or Representative contacts the DRC to speak with a 

Reasonable Accommodation Analyst to begin the interactive Reasonable 

Accommodation process to process the request.

 3. If an employee works with classified information or in a secured area, DOT 

should work to locate a service provider who can obtain the appropriate security 

clearance. 

The DOT’s Disability Resource Center Handbook includes procedures to implement 

the PAS requirement.  When an employee with a disability makes a request for PAS 

as an accommodation in the workplace, the interactive accommodation process is 

initiated.  If required, a disability determination must be made, an analysis completed, 

and an Action Plan developed.  If an Action Plan exists for a different type of PAS then 

what is being asked for or there is a need to make a change to the existing service 

being provided, then after the analysis has been completed, an Action Plan 

Addendum will be developed. 

The employee will be asked to acknowledge receipt of the PAS by signing paperwork 

provided by the vendor describing services provided.  The schedule for this could be 

daily, weekly, monthly, etc. as established in the contract between DOT and the PAS 

vendor.  If the employee feels that there is a discrepancy between what is listed on the 

paperwork and actual services received, they are to notify the DRC immediately. 

Section VI: EEO Complaint and Findings Data 

A. EEO COMPLAINT DATA INVOLVING HARASSMENT 

49 
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: No 

3. If the agency had one or more findings of discrimination alleging harassment 

based on disability status during the last fiscal year, please describe the 

corrective measures taken by the agency. 

FHWA had no findings of Discrimination in FY 2017. 

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: No 

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 finidings of Discrimination in FY 2017. 

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: No 

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 

50 
applicable, accomplishments. 

There are some triggers regarding qualified candidates and selections in certain Trigger 1 MCOs and grade levels for both individuals with disabilities PWD and PWTD. 

Recruitment Practices; FHWA focuses recruitment on distributing competitive 

vacancy announcements.  Barrier(s) Reasonable Accommodation; FHWA needs to develop and market its written 

procedures for Reasonable Accommodations for FHWA employees and applicants. 

Objective(s) 

Increase hiring manager and HR Specialist awareness and knowledge of how to 

use non-competitive hiring authorities for individuals with disabilities (Schedule A; 

“On-the-Spot” within FAA).  Increased awareness of this hiring flexibility will ensure 

we follow the departmental in FY 2014 established goal of 3% onboard persons with 

disabilities and EEOC hiring goal that 2% percent of all new hires at GS 1-10 and 

GS 11-SES should be PWTD. 

Responsible Official(s) 

Performance Standards Address 

the Plan? 

(Yes or No) 

David Lewis, Acting Director, Office of Human 

Resources; Irene Rico, Associate Administrator for 

Civil Rights 

Yes 

Barrier Analysis Process Completed?

(Yes or No) 

Barrier(s) Identified?

(Yes or No) 

Yes Yes 

Sources of Data 

Sources 

Reviewed? 

(Yes or No) 

Identify Information Collected 

Workforce Data Tables Yes 

Complaint Data (Trends) Yes 

Grievance Data (Trends) No 

Findings from Decisions (e.g., 

EEO, Grievance, MSPB, AntiHarassment Processes) No 

Climate Assessment Survey (e.g., 

FEVS) Yes 

Exit Interview Data No 

Focus Groups No 

Interviews No 

Reports (e.g., Congress, EEOC, 

MSPB, GAO, OPM) No 

Other (Please Describe) No 

51 
Target Date Planned Activities Sufficient Modified Completion 

(mm/dd/yyyy) Staffing & Date Date 

Funding (mm/dd/yyyy) (mm/dd/yyyy) 

(Yes or No) 

09/30/2020 Educate hiring managers and HR 

Specialists on available hiring 

flexibilities to include Schedule A 

through the revamped and userfriendly hiring tool kit. 

The FHWA will analyze data 

regarding disability status reporting of 

preference eligible veterans to 

determine what, if any, outreach 

education should be developed to 

encourage identifying as a 

PWD/PWTD. 

Develop step by step procedures on 

the Reasonable Accommodations 

process in easy to use format for 

employees. 

Develop marketing plan for rolling out 

the procedures. 

Yes 

Fiscal Year Accomplishments 

2020 FHWA will report updates and progress in FY18/19/20 MD-715 report. 

4. Please explain the factor(s) that prevented the agency from timely completing

any of the planned activities.

FHWA will report out progress and updates for the upcoming FY 2018, FY 2019 and 

FY 2020 MD-715 report. 

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 2018, FY 2019 and 

FY 2020 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 2018, FY 2019 and 

FY 2020 MD-715 report. 

52